In this Privacy Statement, we have provided information about data collected and used when you:

Purchase a Volkswagen vehicle or otherwise interact with Volkswagen and our Digital Properties, vehicles, products and services

Receive Car-Net® Services (defined below).  

If you are the vehicle owner, you must notify any additional drivers about the privacy practices described in this Statement and if you are the Primary Driver for this vehicle’s Car-Net Services, you must notify any additional drivers of the vehicle about the Car-Net specific privacy practices described herein.

At Volkswagen of America, an operating division of Volkswagen Group of America, Inc., (“VW,” “we,” or “us”), we value your privacy and want you to know how your information will be handled and used.  This Privacy Statement applies to information we obtain from and about individuals interacting with VW websites, mobile applications, and other online services (collectively, our “Digital Properties”); VW vehicles, products and services; hardware and software in your VW vehicle that enables you to receive the personal assistance and telematics-based services provided through VW Car-Net (the “Car-Net Services”); and through other online and offline interactions with VW. However, this Statement does not apply to business contacts or VW job applicants or employees. The privacy statement for VW business contacts and job applicants can be found here.

This Statement does not apply to VW Credit, Inc. (“VCI”) or its products, contracts, and related services. VCI has its own privacy statement, which can be found here.

Below we provide a summary of the general information we collect, how we use it, and to whom it is disclosed. 

Table of Contents

1. From What Sources Do We Collect Information?
2. What Information Do We Collect?
3. How Do We Use Your Information?
4. To Whom Do We Disclose Your Information?
5. Cookies and Other Tracking Technologies
   
6. Mobile Applications
7. Our Commitment to Children’s Privacy
8. External Links
9. Security and retention
10. Changes to this Privacy Statement
11. DriveView™ and Vehicle Choices
    
12. Supplemental State Privacy Rights Information
13. Contact Us

As you interact with VW and its Digital Properties, vehicles, products and services, we may collect certain information from or about you or your vehicle from the following sources:

1. Directly from you, such as when you visit or use VW Digital Properties; use third-party digital properties (including social media sites and sweepstakes microsites); during other interactions such as product and related events, test drives, surveys, and promotion entries; and when you interact with our customer call centers.
2. Cookies and online technologies, such as when you access or use VW Digital Properties, third-party digital properties (including social media sites and sweepstakes microsites), or VW mobile applications.
3. Authorized VW Dealers, such as through leasing, service and other records provided to us by Authorized VW Dealers. 
4. VW-authorized sellers of consumer merchandise.
5. Our affiliates, including VCI (if you finance your VW vehicle purchase or purchase products from VCI) and other companies within the Volkswagen Group family of companies. 
6. Third party service providers, Integrated Content Providers and Optional Third Parties (defined in Sections 4.7 and 4.8 below).
7. Other third parties, such as companies that provide or sell lists of potential vehicle purchasers and current owners, data brokers, business partners, public sources, social media platforms and networks, or other parties that interact with us. 

As you interact with VW and its products and services, we collect different types of information from you based on the interaction, such as when you purchase a vehicle and subscribe to Car-Net services.
The types of information that VW collects about you include:

1. Identifiers, characteristics and other information you provide, including contact information; authentication information you create (such as a Volkswagen ID, date of birth, or other information to verify your identity); your preferences, photographs, user-generated content, and other materials that you may submit; demographic information; account and billing information, including financial data used for payment purposes; and profile information and settings (such as your preferences or information about personalized services).
2. Commercial information regarding vehicle purchase/lease/service, including contact information (such as name, address, telephone number, email); vehicle purchase, lease or service information (such as VIN, make, model, year, dealer, date of purchase or lease, purchase/lease price, vehicle equipment, and service history); and other purchasing or consuming histories or tendencies. 
3. Vehicle usage information, such as vehicle data transmitted from your vehicle or collected or inferred from your use of the vehicle or services, including general vehicle status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle, including its identification, condition, equipment status, or collision information; vehicle/technology usage data (such as usage of lock/unlock and remote start technology); driver behavior data (such as vehicle speed, seat belt use, and information about braking habits); information that you provide when using Car-Net Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers, Integrated Content Providers, and Optional Third Parties related to your vehicle usage.
4. Internet and electronic activity information, such as data gathered by tracking technologies when you visit our Digital Properties (as further described in Section 5 below) and information about your use of Car-Net Services, the Car-Net mobile application, and the Car-Net website.  
5. Geolocation data.
6. Audio, electronic, visual, or similar information, such as call recording for emergency and customer service and voice command data (including any personal data included therein) and the transcripts of conversations you engage in with us via webchat, messaging apps, or social media.
   
7. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, demographics and vehicle usage patterns. 

We collect and use your information for a number of business purposes, such as:

1. To provide you with products and services, such as to provide products and services you request; support your vehicle, products, and services; diagnose, repair, and track service and quality issues; communicate with you about your vehicle, products, or services; install and configure changes and updates to your services; authenticate users of our products and services; verify your eligibility for certain programs or benefits; or to provide you with Car-Net Services. 
2. For our own internal business purposes, such as to evaluate the usage, performance, and safety of our vehicles, products, and services; improve the quality of our vehicles, products, and services and design new products and services; operate our Digital Properties and customize the content; or to maintain internal records.
3. For legal, safety or security reasons, such as to comply with legal requirements; protect the safety, property, or rights of VW and the Volkswagen Group family of companies (such as VCI’s right to repossess its vehicles, including by using GPS data) and those of owners, registered users, drivers, passengers or others; or to prevent and detect fraud or misuse of the vehicles, products, or services.
4. For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties. However, please note that we will not use or disclose precise GPS location data or your driver behavior data for our own marketing purposes or for the marketing purposes of unaffiliated third parties without your affirmative consent.
5. In a de-identified or aggregated format, we may also use or disclose your information in a de-identified or aggregate manner for any purpose.

We also provide your information to third parties who use it for the commercial purpose of marketing their products and services to you.

Please note that for MY19 and older vehicles, we will only use GPS location for purposes of providing Car Net Services to subscribers, complying with legal process, or as otherwise required by law. 

We may disclose your information:

1. Within the Volkswagen Group family of companies. We may disclose your information to Volkswagen Group parents, corporate affiliates, subsidiaries, business units, and other companies that share common ownership (including Volkswagen AG, which is located outside of the United States, and VCI).
2. To third-party service providers. We may disclose your information to service providers that work on behalf of VW, such as advertising agencies, third parties that assist us with marketing efforts, emergency responders, IT providers, and call center service providers.
3. To VW Dealers. We may disclose your information to VW dealers for sales, leasing, and customer service purposes, such as responding to quote requests; for vehicle diagnosis, maintenance, and repair; to schedule service appointments; and to contact you and provide your requested services.
4. To others for legal, security or safety purposes. We may disclose your information to third parties, law enforcement, or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Service and other agreements or those of the Volkswagen Group family of companies; and to protect our rights and the property or safety of our users or third parties. We also may disclose information about you and your vehicle when we have reason to believe that someone is causing injury to or interference with the rights or property of VW, other users of the Digital Properties, or anyone else that could be harmed by such activities.
5. To other companies in connection with a VW corporate transaction. We may disclose your information if some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, in which case we will disclose the information we hold to that company.
6. To third parties for their own marketing purposes. We may disclose your contact information and vehicle identification data to third parties for their own marketing purposes, such as Sirius XM, VW Dealers, and select companies with whom we may partner to offer you products or services. 
7. To Integrated Content Providers. We may disclose your information via the Car-Net® Services to various third parties with whom we contract and to whom you directed us to disclose personal information to provide products and services through VW vehicles (“Integrated Content Providers”) whose services are integral to the Car-Net Services, and without which many of the Car-Net Services would not work.  VW does not create or control the content offered by these Integrated Content Providers, nor does VW determine how they handle your personal information for purposes of providing their services.  The Integrated Content Providers are exclusively responsible for the content and the availability of the content accessible through the Car-Net Services. Integrated Content Providers have the right to use your data for their own purposes and therefore, services from Integrated Content Providers will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use, or disclosure of your personal information by Integrated Content Providers or wish to exercise any rights that you have, please contact the relevant Integrated Content Provider directly at the web address provide below. VW collects and discloses information to these Integrated Content Providers and receives information from these Integrated Content Providers for the purposes described above and in order for you to receive the services and/or content requested. 
   
   The following is a list of the current Car-Net Integrated Content Providers and their respective websites and contact information. This list is subject to change without notice.
   
   – Google Inc., for point-of-interest searching (POI), including voice control, and navigation with Google Earth images : Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA –
 https://policies.google.com/privacy
8. To Optional Third Parties. In addition to the Integrated Content Providers’ services available as part of the Car-Net Services, we may disclose your information to other third parties from which you can obtain or purchase additional services or offerings that we introduce or with whom you independently engage that rely on the Car-Net platform (“Optional Third Parties”).  These Optional Third Party services are not integral to the basic operation of Car-Net Services, but may be added by you in order to receive additional services and/or content from the Car-Net platform. The Optional Third Parties contract directly with you and are exclusively responsible for their services accessible through the Car-Net platform. Optional Third Parties have the right to use your data for their own purposes and therefore, services or offerings from such Optional Third Parties will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use, or disclosure of your personal information or if you wish to exercise any rights that you have, please contact the Optional Third Parties directly. Examples of Optional Third Parties include remote package, fuel or other in-vehicle delivery, car sharing, tolling pricing, usage-based insurance, or other third-party services.
9. To third-party entities that provide online advertising and analytics functionality. We may disclose your information to third parties that provide advertising and analytics services, as further described in Section 5 below.
10. With other third parties that you direct or provide consent.

Our Digital Properties (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about: 

The types of tracking technologies we use and the purposes for which we use them

The types of information we collect using these technologies

How we disclose or make information available to others

Choices you may have regarding these technologies

1. Types of cookies and tracking technologies we use
   Our Digital Properties and the third parties that we authorize may use the following tracking technologies:
   
   - Cookies, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. 
   
   - Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described in Section 5.2 below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
   
   - Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described in Section 5.2 below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
2. Purposes for using these technologies
   We and authorized third parties use these technologies to remember user preferences, login details and browsing behavior; improve the performance of our Digital Properties, products, and services; conduct analytics; provide you with offers that may be of interest to you; track your activity across online properties over time to better understand your preferences and interests; to conduct advertising on our Digital Properties and those of third parties; measure the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with one of our emails; and personalize online content.  For example, we use Google Analytics to help us improve our Digital Properties, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services.  To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
3. Information collected
   These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).
4. Disclosures of your information
   VW may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.
5. Your choices
   Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a VW advertisement and follow the instructions on how to opt out. You can also refuse or delete cookies using your browser settings.  If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired.  Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.  If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from VW or its agents or representatives.
   
   Some browsers have incorporated Do Not Track (“DNT”) preferences.  If you set your browser to signal that you do not wish to be tracked online, we will honor your preference by disabling social media and targeted advertising cookies. 

In addition to mobile applications designed to allow you to use your Car-Net® Services, VW may have mobile applications that you can download to your mobile device or vehicle (“VW Applications”). When you download a VW Application, there may be an opportunity for you to provide us with or for us to obtain information about you or your vehicle. Each VW Application will display a Privacy Statement that will inform you about how any new or different information disclosed via the application will be handled.  Otherwise, information collected via VW Applications will be the information identified above and will be used and disclosed as stated in this Privacy Statement.

Through the Infotainment system, VW may also offer applications developed by third parties, for example Apple CarPlay or Android Auto (“3rd Party Application”). When you download a 3rd Party Application to your mobile device or vehicle, the 3rd Party Application may collect information about you or your vehicle in connection with your download or use of that application. VW is not responsible for the collection or use of information by 3rd Party Applications. We recommend that you carefully review the privacy statement and terms of use of each 3rd Party Application prior to downloading or using them. 

VW does not knowingly collect, use, disclose, or sell the information of children under the age of 16. In the event that we learn that we have collected information from a child under age 16, we will delete that information.  For questions or additional information, please contact us using the information in Section 13 below.

The Digital Properties may contain links to other websites, including social networks, advertisers, VW Dealer websites, VCI websites, other Volkswagen Group websites, other websites operated by VW AG, and websites belonging to other third parties. Some of these sites may share a similar “look and feel” to our Digital Properties. Please be aware that we are not responsible for the privacy practices of other websites. We encourage you to read the privacy statements provided by other websites before you provide information to them. 

VW maintains reasonable safeguards to protect your information.  Some services, including Car-Net® Services, may involve the transmission of voice and data from your VW vehicle over wireless and cellular telephone networks and therefore, we cannot guarantee the privacy and security of conversations or data transmitted to and from your VW vehicle.

 Your information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety, and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as  to demonstrate our business practices and contractual obligations or provide you with information about our products and services in case of interest. 

From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you periodically to check this site to learn about the information we collect, use, and disclose. Your continued use of any of our Digital Properties, products or services affirms your agreement to such changes.

1. DriveView™ If you are eligible for and opt-in to DriveView (a usage-based insurance program), VW will collect and use commercial and electronic network activity information collected through Car-Net Services about your driving behavior, such as speed, braking and seat belt usage, and GPS location in order to assess your driving and routinely provide you a DriveView score (i.e. a score based on certain factors that are considered higher indicators of risk of collision, such as hard braking, nighttime driving, idle time and high speed).  We will collect this data directly from you and your use of the Car-Net technologies. We also will use aggregated data to conduct driver behavior modeling (for example, comparing drivers across different states). If you opt-in and direct us to do so, we also will send your driver behavior and GPS location data to our insurance company partners for consideration. They may offer discounts depending on your driving record. You can also opt-in to DriveView and direct us to disclose your driving data and GPS location data to your existing insurance carrier.  We will provide it only at your direction, but you may discontinue disclosure at any time by un-enrolling in DriveView.
   Please visit the Car-Net website for more information about the DriveView program, eligibility requirements and how you can participate.
2. Vehicle Choices
   You can discontinue the Car-Net Services data collection described in this Privacy Statement at any time by unenrolling your vehicle from Car-Net. However, this will result in loss of Car-Net Services. For Model Year 2020 and newer vehicles, you can unenroll from Car-Net via the Car-Net website, Car-Net mobile app or by calling Car-Net Response Center at 1-833-648-2735. For Model Year 2019 and older vehicles, you can unenroll by calling 1-877-820-2290.
   
   Please note that the information stored in your VW vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your VW vehicle or mobile device, and thus may be deleted, altered, or transferred.
   
   Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.

In addition to the details provided above about the information we collect and how we use and disclose it, below is a list of the categories of personal information collected and for each category, the categories of third parties to whom we disclosed it for a business or commercial purpose (as defined under applicable law). 
Although we have not "sold" personal information for money in the past 12 months, we disclose information for targeted advertising purposes and in other situations that may constitute a "sale" or “sharing” as defined under applicable law.